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April 15, 1993
MEMORANDUM TO: REGIONAL ADMINISTRATORS
THROUGH: LEO CAREY
Director of Field Programs
FROM: ROGER A. CLARK
Director of Compliance Programs
SUBJECT: Applicability of Permit-Required Confined Space Standard
to Electrical Utility Underground Workplaces
The Edison Electric Institute (EEI) has asked Acting Assistant Secretary
Zeigler to stay the confined space standard as applied to electric and steam
utility underground workplaces such as manholes and vaults and to clarify
OSHA's enforcement policy concerning the application of the confined space
standard to these facilities. We have informed EEI that enforcement of the
confined space standard in these facilities will be restricted, and a letter
clarifying the agency's position is being prepared for issuance over the
Assistant Secretary's signature. In the interim, please contact H. Berrien
Zettler, the Deputy Director for Compliance Programs, prior to issuing any
citations for confined space violations in these facilities. I will forward
copies of Acting Assistant Secretary Zeigler's letter when it is issued.
Please distribute this memo to the appropriate state plan officials. If you
have any questions, please contact Ray Donnelly or Art Buchanan of my staff
at (202) 219-8041.
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